Paul M. McManus v. Ron Neal, 2015 U.S. App. LEXIS 2389

McManus was convicted of murdering his estranged wife Melissa and two daughters and sentenced to death after a jury trial in Indiana.
On postconviction review, Indiana courts evaluated Atkins claim and found no intellectual disability, but McManus argued his trial competency was compromised.
During trial McManus experienced multiple panic attacks; he was treated with psychotropic medications whose cognitive effects raised doubt about his fitness to proceed.
The trial judge did not order a formal competency evaluation and proceeded despite concerns; defense motions for mistrial or continuance were denied.
Postconviction courts eventually found McManus intellectually disabled, but the Indiana Supreme Court reversed, reinstating the death sentence; the federal district court denied relief on Atkins but granted relief on competency claims.
The Seventh Circuit held: (i) Atkins claim fails; (ii) the state courts unreasonably applied due-process standards to adjudicate competency; (iii) the Riggins/drug-induced-stupor claim was not resolved in McManus’s favor on habeas review; (iv) the claim of ineffective assistance for not presenting additional mitigating evidence was not reached due to the remedy on competency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the state courts properly applied Atkins	McManus argues Atkins requires disability; the state courts erred in denying disability.	State courts reasonably applied Atkins and relied on IQ/adaptive-functioning evidence.	No habeas relief on Atkins; state courts correctly applied Atkins standard.
Whether the state courts properly adjudicated competency to stand trial	Panic attacks and medications rendered McManus incompetent; trial violated Dusky due process.	Trial court adequately evaluated McManus and competency; no due-process violation.	State courts unreasonably applied due-process standards for competency; remedy granted.
Whether McManus was subjected to a drug-induced stupor before the jury	Medication produced impairment affecting trial fairness in violation of due process (Riggins).	No claim established that medications produced a drug-induced stupor impairing the trial.	Riggins issue not decisive to the outcome; remedy focused on competency findings.
Whether trial counsel were ineffective for not presenting more evidence of intellectual disability at sentencing	Additional disability evidence during penalty phase could have altered the sentence.	Existing evidence from guilt phase was incorporated into penalty phase; no deficiency in representation.	Not reached due to remand on competency; the claim remains unresolved in the opinion.

Atkins v. Virginia, 536 U.S. 304 (2002) (death penalty cannot be imposed on intellectually disabled defendants)
Hall v. Florida, 134 S. Ct. 1986 (2014) (margin of error and medical standards inform but do not dictate disability determinations)
Dusky v. United States, 362 U.S. 402 (1960) (defendant must have rational and factual understanding and ability to assist in defense)
Pate v. Robinson, 383 U.S. 375 (1966) (necessity of competency evaluations when doubt exists)
Drope v. Missouri, 420 U.S. 162 (1975) (due process requires proper competency determination and hearings)
Wilson v. Corcoran, 131 S. Ct. 13 (2010) (habeas review standards and state-court proceedings)